ML20206Q591

Responds to Noncompliance Noted in Insp Repts 50-295/86-26 & 50-304/86-26 on 861027-1120 & 870217.Corrective Actions: Supplemental Work Instructions Will Be Attached to Work Request & Diesel Generator Procedures Reviewed & Rewritten

ML20206Q591
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/20/1987
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20206Q564	List: ML20206Q559 ML20206Q591
References
2878K, NUDOCS 8704210427
Download: ML20206Q591 (5)

Text

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Commonwealth Edison

• * [,4 ) One First Nabonal Plaza Chicago, Illinois

( s~/ Address

' Reply t): Post Omce Box 767 Chicago, Illinois 60690 - 0767 March 20, 1987 Mr. James G. Keppler.

Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Zion Nuclear Power Station Units 1 and 2 Response to Inspection Report Nos.

No. 50-295/86026 and 50-304/86026 NRC Docket No. 50-295 and 50-304 References (a): February 18, 1987 letter from N.J. Chrissotimos to Cordell Reed (b): February 6, 1987 letter from P. C. LeBlond to J. G. Keppler

Dear Mr. Keppler:

This letter is in response to the inspection conducted by J.W. Muffet, H.A. Walker, and J.M. Jacobson of your office on October 27, November 6, 11, 12, 14 and 20, 1986 and February 17, 1987, of activities at Zion Nuclear Power Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. Commonwealth Edison Company's response ,

to these violations are provided in the attachment to this letter, l l

Reference (b) transmitted Commonwealth Edison Company's formal report I regarding the findings and conclusions of our investigation of the failure of Zion's IB diesel generator.

If you have any further questions on this matter, please direct them to this office.

Very t ly yours, 8704210427 870414 .

DR ADOCK 0500 5

. L. Farrar Director of Nuclear Licensing im i Attachment cc: NRC Resident Inspector - Zion J. A. Norris - NRR 2878K MAR 2 a 137

ATTACISBNT 4

ZION NUCLEAR POWER STATION 4

RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOMPLIANCE #1 As a result of the inspection conducted on October 27, November 6, i 11, 12, 14 and 20, 1986, and February 17, 1987, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC

Enforcement Actions-(1985), the following violation was identified

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1. 10 CFR 50, Appendix B,' Criterion V, as implemented by the Commonwealth-Edison Quality Assurance Program requires that-activities affecting quality be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances.and that those activities be accomplished in accordance with the instructions, procedures or. drawings.

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a. Contrary to the above, repairs made to Unit 1 Diesel IB were accomplished with inappropriate work instructions that contributed to inadequate descriptions of certain work functions, confusion, and missing Quality Control hold points.

b. Contrary to the above, some Unit 1 Diesel IB work packages did not contain " sign offs" by the maintenance mechanic as required by the 5 instructions attached to the Nuclear Work Request.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED

a. Initial corrective actions were to check the torque values on the lower articulating rod bolts for all Diesel Generators. Any bolts

that moved with less than 1140 ft-lbs of torque were replaced.

4 Every safety re4ated work request was reviewed for adequate work instructions including those already in progress.

b. As stated in CECO's investigation report on the IB Diesel Generator Failure, meetings have been held with the Maintenance Foremen to

. re-emphasize that work will not be. considered as completed until all applicable sign offs have been obtained. It has also been emphasized that no deviation from the scope of work is allowed without first obtaining the appropriate approval for the work instructions in use,

c. The requirements on maintaining the " sign offs" current with the actual work completed has been stressed to the maintenance personnel.

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CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION

a. For safety related work requests that require the inclusion of instructions covered in a technical manual, supplemental work instructions (traveller) will be attached to the work request by the work analyst. This will specify the section of the technical manual to be utilized.

b. There will be no deviations from the scope of work without obtaining the proper approval. This approval will always be appropriate to the type of work instructions in use. (e.g., maintenance procedures vs approved work request travellers.)

c. Work is not considered to be finished without the appropriate signoffs completed, hold points satisfied, and documentation complete. These constraints have always been required prior to returning equipment to operable service. However, this policy will now be administrative 1y extended to maintenance testing.

d. The procedures governing the overhaul and repair of the diesel generators will be reviewed and rewritten as necessary. This review / revision will include a consideration of the procedure format. The procedure's verbage will be arranged to minimize the Possibility of not properly associating the work performed with a specific hold point or sign-off. This will reduce the potential for ,

missed QC hold-point signoffs in work packages.  !

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

a. The administrative controls associated with the maintenance work I I

instruction process described above will be in place by April 30, 1987. I

b. The diesel generator overhaul and repair procedures will be reviewed / revised as required by October 31, 1987. A vendor representative will be present for all major diesel generator maintenance work until the revised procedures have been implemented.

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-ITEM OF NONCOMPLIANCE #2 As a result of the inspe'etion conducted on October 27, November 6, 11,12,14 and 20,1986, .and Febrt.ary 17, 1987, and in accordance with 10 CFR i- Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1985), the following violation was identfied:

, 2. 10 CFR, Appendix B, Criterica X, as ' implemented by the Commonwealth

! Edison QA program, requires that a program for inspection.of activities affecting quality be established and executed to verify conformance with documented instruction, procedures and drawings for accomplishing the activity. Examinations, measurements and tests shall be performed as necessary to assure quality and where " hold points" are assigned, work will not proceed past the designated " hold points" without proper release.

a. Contrary to the above, work proceeded past-13 Quality control hold points that were not properly released for inspection, as documented in five Nuclear Work Request packages for Unit 1 IB Diesel.

b. Contrary to the above, Unit 1 1B Diesel was released for testing without verification that. inspection was completed and acceptable for seven maintenance related Nuclear Work Requests.-

I CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED

! a. As stated in Ceco's investigation report dated January 28, 1987, all l Quality control Inspectors were required to read and sign a policy statement on Hold Points stipulating that hold points should be signed on the jobs as soon as possible after the inspection. The QC Supervisor also issued a memo to the inspectors clarifying that approval of a work instruction revision is required when performing work out of sequence or not performing work as specified in the work package.

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< b. The maintenance foremen have been informed, as stated above, about j the requirements for the completion of all applicable hold points and sign-offs prior to performing any maintenance test. The maintenance foremen have also been instructed to review all open work packages associated with a component prior to operating that component for maintenance test purposes. In addition, maintenance foreman have been instructed to utilize Quality Control personnel, if necessary, to review major work packages to ensure proper work-completion prior to equipment operation.

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CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION I 1

a. The procedures governing the overhaul and repair of the diesel generators will be reviewed and rewritten as necessary. This review / revision will include a consideration of the procedure l format. The procedure's verbage will be arranged to minimize the ,

possibility of not properly associating the work performed with a j specific hold point or sign-off. This will reduce the potential for )

missed QC hold-pcint signoffs in work packages. j

b. The Commonwealth Edison equipment out of service program does not require the Quality release of a work request package prior to operating equipment for a maintenance test. A Quality release must be obtained prior to performing any equipment operability testing.

However, Zion Station is strengthening the controls over the status I

of the equipment that is to be run for maintenance testing purposes. The Assistant Superintendent of Maintenance will develop a formal administrative control to ensure and document that work i packages are reviewed for the adequate completion of work prior to ,

performing a maintenance _ test. This will include any required l inspections or documentation.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

a. The diesel generator overhaul and repair procedures will be reviewed / revised as required by October 31, 1987.

b. The administrative controls for ensuring work package completion prior to maintenance testing will be in place by April 30, 1987.

2878K

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